Comment submitted by A. N. Sparks, Georgia Cooperative Extension

As I have already provided considerable information for this section 18 request, I will try to keep my comments brief. Recent actions have made this section 18 even more critical. Two previously efficacious products have been, or are in the process of being, removed for this market. DuPont has declined support for renewal of a section 18 for use of Avaunt on collards, and DOW is removing the leafy Brassica crop group from the SpinTor label in Georgia. These actions are being taken for resistance management in diamondback moth. This leaves our producers with a single new chemistry (Proclaim) and several older chemistries (B.t.s, Lannate, Endosulfan). This will result in severe resistance pressure on Proclaim, and it is not likely that any product would last long under those conditions (our experience with SpinTor being the first of the new products on the market and the severe resistance that has occurred provides evidence of this problem). B.t.s are already heavily used in resistance management, but can not provide adequate crop protection under the pest pressure experienced in south Georgia. Renewed use of Lannate (and to a lesser degree Endosulfan) generally provides good control for a short period of time before resistance reappears. In the absence of a section 18 for Tesoro, the likely scenario will be heavy selection pressure for resistance to the few products we have available, followed by increased use as these products as they become less efficacious, followed by control failures and severe losses in all crops attacked by diamondback moth. It is my understanding that EPA has some concerns about potential ecological effects of Tesoro. While I am not fully qualified to address these concerns, I would encourage evaluation of these concerns in comparison to the likely impact of alternatives in actual production practices (heavy use of Proclaim and Lannate and likely heavy use of endosulfan) rather than an unrealistic evaluation compared to no potential environmental or health effects.